Memorandum by the Council for the Protection
of Rural England (UWP 33)
URBAN WHITE PAPER
1. The Urban White Paper expected later
in 2000 will be one of the most important influences on the countryside
and the Government's wider environmental objectives to be produced
for many years. The fact that this is no longer regarded as a
paradoxical statement bears testimony to the advance in recent
years of policy thinking on the links between urban and rural
areas, and recognition of the widespread benefits of an "urban
renaissance". CPRE warmly welcomes this inquiry, therefore,
which when linked to the inquiry into the Rural White Paper, has
the potential to bring major benefits to communities across the
whole of England and to harnessing new development for the benefit
of both urban renewal and better protection of the countryside.
2. CPRE has a longstanding interest in the
relationship between town and country, from the concerns for urban
sprawl and wasteful use of land which triggered CPRE's foundation
in the 1920's, through to the establishment of Green Belts as
a means of facilitating urban renewal as well as protecting rural
land. In recent years we have highlighted the wider benefits of
urban renewal for the countryside and the better use of resources,
and have pioneered efforts to enhance the capacity of towns and
cities to accommodate development in ways which improve the quality
of life. Our Assistant Director (Policy), Tony Burton, is also
a member of the Government's Urban Task Force and made major contributions
to presenting the Task Force's final report and its mock Urban
PPG (enclosed). Our views are summarised in the enclosed literature
(Urban Footprints, Urban Exodus, Going to town, Room to live,
Renaissance Pays) and have now entered the mainstream of political
and professional thinking. We identify an overwhelming consensus
across a diverse set of interests in favour of the urban renaissance.
Our evidence focuses, therefore, not on the case for urban renewal
but on the means to achieve it.
3. We identify the following priorities
for implementing an urban renaissance.
COMMITMENT TO
THE URBAN
TASK FORCE
REPORT
4. The Urban Task Force has provided over
100 recommendations for changes to public policy and approach
which are grounded in a detailed and expert analysis of the issues.
We commend it unequivocally to the committee. The Urban White
Paper will be the most important means of addressing this comprehensive
agenda as well as wider issues which were outside the Task Force's
remit and which could only be referred to en passant (eg
educational standards). The key indicator of the Government's
commitment will be the purchase of the White Paper on recommendations
from the Task force where responsibility for implementation lies
outside the DETR. Fiscal, education, social and competitiveness
policies in particular are central to an urban renaissance. That
the Urban White Paper should provide a coherent, Government-wide
commitment to an urban renaissance is the single most important
priority. This is where it will add most value to the myriad individual
announcements and decisions which the Government makes that affect
urban areas.
5. The Task Force's recommendations should
ideally be taken as a piece. There are risks in seeking to prioritise
or separate them out when a key finding of the Task Force was
the interconnected nature of the policy issues and solutions.
The cumulative benefit of the many recommendations will be much
greater than the individual benefits from any one of them. Nevertheless,
CPRE identifies the following 10 measures as ones where the Government
should be taking an early initiative, which in some cases should
pre-date the Urban White Paper.
A planning measure—announce the intention
to produce an Urban PPG (using the Task Force's mock PPG as a
starting point) and seek initial views on its content so a formal
draft can be issued at the same time as the Urban White Paper.
A fiscal measure—announce harmonisation
of VAT on new building and refurbishment in the March Budget.
A land measure—support local planning
authorities in reviewing existing greenfield allocations in plan
reviews and withdrawing those which do not fit in with current
policy objectives in the revised PPG3.
A regional measure—announce a role for
the eight RDA economic strategies in promoting more even regional
growth across the country and provide an overarching national
framework to guide regional development priorities.
A transport measure—set a target for Local
Transport Plans in new guidance that at least 65 per cent of expenditure
should be on projects that benefit pedestrians, cyclists and public
transport users and urge the use of future Local Transport Plans
to promote an urban renaissance.
An expenditure measure—address urban renaissance
in an overarching way as part of the Spending Review 2000 process
which is now underway—it is disappointing that a cross-cutting
urban renaissance review has not been included in the Spending
Review and it is not referred to in the internal guidance on "common
issues" provided by the Treasury to Government departments.
A "real world" measure—reject
the Crow report on regional planning for the South East and set
an objective to reduce the level of migration to the south and
promote more even development around the country.
A "good practice" measure—publish
and disseminate—including through local seminars—the
long promised guides to local planning authorities on both design
and urban capacity studies and require their use in plan preparation.
A machinery of Government measure—establish
an Urban Policy Board with key Ministers and representatives from
the Seven Cities group to advise on the Urban White Paper preparation.
An urban design measure—announce a review
of planning and funding guidelines to promote good urban design
and clarify the role of the new Commission for Architecture and
the Built Environment in raising national standards.
ADDRESSING EXCESSIVE
GREENFIELD ALLOCATIONS
6. The Urban White Paper needs to deliver
a step change in the attractiveness of urban areas to people,
businesses and developers. This will require strong action to
remove current incentives towards greenfield development and to
address the overhang of existing planning allocations on greenfield
sites for housing and economic development which continues to
distract investment from urban areas.
7. The Urban Task Force addressed the scale
of housing land "in the pipeline" on greenfield sites.
Work carried out by the Royal Town Planning Institute and recorded
in the Task Force's final report Towards an Urban Renaissance
shows (pps186-7) that in 1998 on a conservative estimate:
— 262,000 dwellings had been granted
planning permission but not yet implemented;
— land for 240,000 dwellings had been
allocated in Local Plans; and
— a further 156,000 dwellings are likely
to be built as a result of replacement plans.
8. Including 220,000 dwellings built on
greenfield sites since 1996, the sum total of these allocations
(circa 800,000 dwellings) already account for over half the greenfield
land allocations that can be expected over the whole period 1996-2021
(if the Government is to achieve its target of developing 60 per
cent of houses on previously used sites and the household projections
are met in terms of the number of new homes). The Task Force comments:
"Such high levels of greenfield housing in the pipeline have
important implications for the ability to ensure high levels of
ongoing brownfield housing."
9. This is confirmed by the report of the
Social Exclusion Unit's Policy Action Team 7 report on unpopular
housing which identifies the need for strong planning restraint
on rural land to underpin measures to raise demand in urban areas.
10. Similar issues arise in relation to
allocations for employment land and for retail development. There
is a vast reserve of land allocated for economic development which
has not been implemented and which is undermining the scope for
urban renewal. Current policies are too weak to prevent this problem
continuing (see our Towards Sustainable Economic Development
(1999) and examples in Annex 1). In addition to strengthening
the policy base we believe there is a need for stronger safeguards
over abuse, including a strengthening of the call-in mechanism
and introduction of a third party right of appeal. Further details
are provided in our Planning for People (enclosed).
11. The positive measures for an urban renaissance
in the Urban White Paper also need to be underpinned by policies
in Regional Planning Guidance for making better use of urban land
and buildings. CPRE's recent analysis of emerging RPG for the
period 1996-2016 suggests that only 56 per cent of new housing
will be on previously developed land and buildings (compared to
the Government's target of 60 per cent and the current figure
of 55 per cent) and the development of almost 700 sq km of rural
land under 1.5 million houses is being planned. Further details
are provided in Annex 2.
CHAMPIONING URBAN
REGENERATION
12. The Urban White Paper needs to provide
a new champion for the urban regeneration process itself and the
economic and employment benefits it brings. As an economic activity
in its own right, the urban regeneration sector has a low profile
no clear identity.
13. Even using cautious assumptions in defining
the urban regeneration sector a CPRE study identified that:
— 220,000 people are directly employed
in the urban regeneration sector—this is more than in insurance,
car assembly or utilities and equivalent to employment in the
computer sector;
— over 550,000 jobs rely on the urban
regeneration sector either directly or indirectly.
— the urban regeneration sector contributes
£12.5 billion to the economy;
— urban regeneration accounts for one
in every four construction jobs; and
— the urban regeneration sector can
be expected to generate 7,000 new jobs a year between 1996 and
2006, bringing the total number employed to 627,000.
14. There is a need to give the urban regeneration
sector a stronger identity if the wider benefits of an urban renaissance
are to be achieved. It is a major employer which provides a powerful
means of creating new jobs and economic wealth as well as improving
the quality of urban living and protecting the countryside. The
success of the urban regeneration industries should be central
to the Urban White Paper. The sector needs to be recognised for
the social and environmental benefits it brings as well as its
contribution to economic prosperity and as a shining example of
how to integrate these objectives and encourage more sustainable
development.
15. This requires:
— a champion within the Government—the
sponsorship and promotion of the construction sector in both the
Department of Trade & Industry and the Department of the Environment,
Transport and the Regions should be combined and expanded to provide
a champion within the Government for the urban regeneration sector
as a whole, and for more sustainable construction;
— more coherence in Government spending—the
Public Service Agreements agreed by Government Departments should
include clear objectives for maximising the economic, social and
environmental benefits of spending on urban regeneration across
Whitehall;
— regional identity—the new Regional
Development Agencies should establish clear urban regeneration
objectives as the basis of their economic strategies and as a
major contributor to more sustainable development and the spatial
objectives established in Regional Planning Guidance;
— a regular survey to track performance—the
urban regeneration sector should be the subject of a regular survey
of leading practitioners and companies which could be organised
by the voluntary or public sectors;
— business support—long term
corporate investment in regeneration initiatives working in harness
with the voluntary and public sectors and encouraged by tax incentives
should become more normal practice as businesses adopt a more
strategic approach to "community affairs";
— an "urban living" exhibition—building
on the success of the Ideal Home Show, a regular event stimulating
interest and new thinking in urban regeneration and city living
could become a catalyst for changing perceptions and championing
the sector.
OTHER ISSUES
16. The Urban White Paper also needs to:
— result in a clearer understanding
of the geography of public policy and expenditure decisions in
conjunction with the Rural White Paper. The most important influences
on the future of both urban and rural areas are often public policy
and expenditure decisions which do not have a specific urban or
rural association. Yet, by bending mainstream budgets or "proofing"
public policy for its urban and rural effects we can secure positive
advances. It is essential, therefore, that more attention, perhaps
through a "spatial impact assessment", is given to the
geographical impact of decisions in areas such as health, education
and social security which are currently too often blind to their
spatial implications.
— take a pro-active lead in supporting
and improving the suburbs—the urban policy agenda needs
to bring benefits to "every street in every town" and
more attention should be paid to the suburbs (where it is estimated
that half the population lives). The "10 principles for Urban
Design" proposed by the Urban Task Force need to be applied
with vigour to suburban areas and positive measures need to be
taken over a long period of time to:
gradually retrofit existing suburbs which are on
the decline through revitalisation of local services and community
facilities, making better use of existing buildings and increasing
densities, especially around local centres;
invigorate local communities through, for example,
establishing a parish or neighbourhood council network where one
does not always exist;
— stimulate a more positive approach
by local planning authorities to expanding urban capacity and
increasing densities. Urban capacity studies should be a requirement
in the preparation of all development plans and the best practice
guidance promised by DETR should be issued without delay. Government
Regional Offices should take a strong line against local planning
authorities which do not address urban capacity issues in a more
creative way and undertake urban capacity studies. Similar measures
are being proposed in the Urban Regeneration and Countryside Protection
Private Members Bill;
— support efforts to integrate policy
development in urban and rural areas. CPRE and WWF-UK have, for
example, recently pioneered a methodology for bringing urban and
rural people together to identify shared concerns and perspectives
and contribute to policy development. This approach needs to be
taken up by local government (including through the Local Government
Association's proposed urban/rural compacts), Regional Development
Agencies and others.
Annex 1
GREENFIELD ALLOCATIONS FOR ECONOMIC DEVELOPMENT
PLANNING THE
LOCATION AND
SUPPLY OF
EMPLOYMENT LAND
AT THE
REGIONAL LEVEL—REGIONAL
PLANNING GUIDANCE
FOR THE
NORTH WEST
The Government Office for the North West (GONW)
has found itself in a position of referee between local authorities
in the region which, combined, have attempted to allocate more
land for employment than the region requires. In drawing up regional
guidance, GONW had hoped to identify strategically important employment
sites in the region which could then be prioritised for development
through the RPG. However, the local authorities proposed too many
sites and could not agree priorities, so the published RPG 13
left the site prioritisation process incomplete. GONW has sought
to limit the number of employment sites of each kind available
in the region at any one time. It is monitoring the proposed allocation
of sites in development plans, including objecting to sites which
have prematurely been put forward under the headings used in RPG
13 (such as in Vale Royal district).
Unfortunately, the environmentally sound features
of the regional guidance are at risk from local authorities in
the region, which have collectively failed to implement RPG 13
in practice over the last three years. In April 1998 the local
authorities published a list identifying nearly 70 sites for employment
provision, but did not prioritise those for development. They
therefore failed to discharge the requirements of RPG 13. Meanwhile,
the local authorities' regional development arm (Inward), working
with the national investment agency English Partnerships, proposed
a different agenda with a list of 180 sites over eight hectares
suitable for development from an economic investment angle, including
greenfield sites. The list of sites is unrelated to the RPG categories.
The criteria for and process of employment land allocation are
now back in the melting pot, with a revision to RPG 13 under way
and the new Regional Development Agency (subsuming the roles of
English Partnerships and Inward) preparing its own regional economic
strategy.
WEAK STRATEGIC
PLANNING AT
THE REGIONAL
LEVEL—RELEASE
OF GREENFIELD
SITES WHEN
AMPLE DEGRADED
LAND AVAILABLE
IN THE
NORTH EAST
In North East England the enthusiasm for provision
of employment-generating development on greenfield sites as well
as previously developed land is widely shared across the political
landscape. Around 5,620 hectares of land in the region already
have planning permission for business and industrial development
or have been allocated for this in deposit or adopted plans. This
far exceeds any realistic prospect of the amount of development
which will take place in the foreseeable future, especially in
the Tees Valley. Substantial greenfield sites have also been allocated
by authorities such as North Tyneside, the City of Newcastle and
Sunderland. In Newcastle, the City Council is promoting the development
of almost 500 ha of former Green Belt land (the "Northern
Development Area") for mixed use development, including business
and industrial uses, in the face of strong opposition on environmental
grounds and concern that it will jeopardise the regeneration of
run-down parts of the City and North Tyneside. There has been
no thorough assessment of the likelihood of industrial development
on allocated sites, or consideration of acceptable alternative
uses, and there is no phasing mechanism to enable priority to
be given to the use of previously used sites. Large amounts of
degraded land will therefore be bypassed by the development process
and remain in poor condition for some time to come. Also, the
planning system itself will to some extent be bypassed: the large
areas of permitted and allocated land results in an inability
of planning control to steer development to preferred locations,
with the result that development agencies and large employers
will shape the pattern of future development instead.
RELEASE OF
GREENFIELD SITES
WHEN AMPLE
DEGRADED LAND
AVAILABLE LOCALLY—DONCASTER
UNITARY DEVELOPMENT
PLAN
Doncaster Metropolitan Borough Council states
in its deposited Unitary Development Plan (UDP) that it "is
determined to ensure that land supply does not act as a constraint
upon job creation". It has pursued this idea with vigour.
Against recent rates of land take up for employment purposes of
19 hectares per annum, the deposited Plan proposed to release
enough land to supply 40 hectares per annum up to 2006, with an
additional 80 hectares in reserve. Striking features of the arrangement
are: the substantial over-allocation of land, the preponderance
of greenfield sites despite regeneration opportunities, and allocation
of large amounts of land in road corridors.
The Doncaster UDP provides for 550 hectares
of employment land on greenfield sites, plus the 80 ha in reserve
for use by 2006. The fact that some of the greenfield sites are
also in the Green Belt did not trouble the Council or the UDP
Inspector, the latter merely observing that the over-allocation
of land "could well set the general context for the consideration
of objections to particular employment sites, particularly in
relation to Green Belt issues" (Report para 2.14). These
are scarcely the "very special circumstances" required
by PPG 2 Green Belts to be shown before such land should be released.
Greenfield sites represented nearly 75 per cent of the total allocation,
in an area well known for its large supply of derelict land (230
ha) mainly in areas affected by colliery closures.
CONFLICTING EVIDENCE
ON EMPLOYMENT
LAND REQUIREMENTS—DEVON
COUNTY STRUCTURE
PLAN
Devon County Council published the Deposit Draft
of the first review of its Structure Plan in 1996 with a policy
proposal that 775 ha of employment land should be provided for
the period 1995-2011. The County Council opted for this amount
of land supply on the basis of: past rates of employment land
take-up in the county; the land requirements arising from growth
in the workforce; and its own policy objectives. To the extent
that these gave pointers to future land requirements, the results
were inconclusive or divergent. For example, figures of past rates
of employment land take-up implied a range of requirements between
128 and 784 ha, with a mean of 444 ha. Given that the starting
point for the new plan was from the lowest level of activity in
recent years, a provision of 775 ha would be exceptionally generous.
The Panel holding the Examination-in-Public
into the Structure Plan went through the motions of expressing
concern that if there was large scale over-allocation of employment
land this would not be environmentally sustainable, would blight
land and could cause preferred brownfield sites to be left idle.
It also accepted that historic land take-up rates lagged far behind
allocations in plans. Nevertheless, the Panel broadly supported
what it agreed were proposed allocations "at the very upper
end of the scale", because "it is clearly essential
to ensure that land supply problems do not deter expansion and
inward investment proposals. A liberal supply of land in those
areas most likely to attract new investment would enable a range
and choice of provision". To reflect its modest concern about
over-allocation in some places, the Panel recommended a reduction
from 775 ha to 740 ha, arguing that "there is no real prospect
of a surge in economic investment fuelling a greater level of
in migration". The adopted plan reduced the allocation to
775 ha. With land supply on this vast scale it is the market,
not the planning system, which will shape the pattern of development
in Devon.
Annex 2
HOUSING AND EMERGING RPG
The table below summarises the current state
of play in the review of Regional Planning Guidance (RPG) across
England. Using the latest available information, it sets out the
key facts and figures relating to plans for future housing development
covering the period from 1996 to 2016 (see notes at foot of table).
The housing figures for East Anglia and the South East are taken
from the Panel reports on draft RPG and it is assumed that London
will meet the household projections.
| Region | Household
Projections1
| Housing
Level | Excess
housing
| Urban
recycling
target |
Greenfield
housing |
| East Anglia | 201,000 | 232,477*
| 31,477 | 40% | 139,486
|
| South East | 916,000 | 1,098,500
| 182,500 | 50% | 549,250
|
| Greater London | 518,000 |
518,000 | 0 | 90% |
51,800 |
| North East | 102,000 | 119,000
| 17,000 | 60% | 47,600
|
| South West | 411,000 | 373,000
| -38,000 | 36% | 238,720
|
| East Midlands | 285,000 | 290,400
| 5,400 | 45% | 159,720
|
| Yorks/Humber | 246,000 | 279,700**
| 33,700 | 60% | 111,880
|
| North West | 221,000 | 332,000***
| 111,000 | 60%+ | 132,800
|
| West Midlands | 226,000 | 257,000****
| 31,000 | 61%+ | 100,230
|
| TOTALS | 3,126,000
| 3,500,077 | 374,078
| 56% | 1,531,486
|
| | |
| | |
Notes
*Figure derived from a planning period 1995-2016.
**Figure derived from a planning period 1998-2016.
***Figure based on mid-point of proposed range which takes
account of projected clearance levels.
****Figure derived from a planning period 1991-2011 adjusted
to reflect the 1996-based household projections.
+Figure to 2003 taken from NW RDA Strategy.
++Figure taken from existing RPG.
1 Source: DETR (1999) Projections of households
in England to 2021, SO.
|
